Privacy & Security Policy

Effective: January 27, 2016

Overview

Integrated Technology Group (“ITG”) provides the EduWave (“EduWave”) education platform (the “Service”) with permission of the local schools, school systems, local school districts, teachers, or other responsible education authorities who subscribe for our Service (the “Named Subscriber”). These Services are made available to you (the “User”) subject to these Terms and Conditions (the “Agreement”). By using and accessing this Service located at www.itgsolutions.com, you are agreeing to be bound by, and to comply with, these Terms and Conditions and any other terms and conditions or terms of service posted on any individual page of this Service.

Our Service is a cloud-based education platform that includes a learning management system, content management and delivery system, content authoring and publishing, instructional management system, student information system, school and class management, communication and collaboration tools, assessment, and evaluation tools, reporting, and much more.

We facilitate student and teacher engagement both inside and outside of the classroom using multiple communication, collaboration, and social networking tools allowing shared interaction among class participants, parents, teachers, administrators, and other interested parties [who are authorized].

Usage by Students

We require schools, districts, or teachers to obtain consent from parents in order for a student to make use of our Services. If a student is under the age of 13, a parent or legal guardian must give consent for the child to use our Services.

We collect limited personal information from minor students only where that student’s school, district, or teacher has contracted with us to collect personal information for the use and benefit of the learning environment. For more information on COPPA, please see www.ftc.gov/privacy.

You must be authorized to use our Services. It is your responsibility not to disclose your activation code, user name and password to anyone (other than to your parent or guardian, if you are a student). It is your responsibility to use this Service only for the purpose in which it was intended. Any use of the Service not in accordance with the intended purpose is prohibited.

Opt-out

If you are the parent or guardian of a student using our Services and cease to agree with our Terms & Conditions and privacy policy at some point in the future, you may opt-out by contacting the Named Subscriber (typically your school administrator) through which you are making access to our Service.

Standard Provisions

If you are a student, the following provisions also apply:

Be careful who you share your information with while using our Services.

Your parent or guardian must read these Terms and Conditions before you begin to use our Services.

Because you are a student, you should only register for and access our Services as a student registrant using the login and password that is provided to you, and not as another student, a teacher, parent, or any other category of user.

If you are accessing our Services on behalf of a Named Subscriber such as a School or a School District, the following provisions also apply:

You represent and warrant that you are solely responsible for complying with the Child Online Privacy Protection Act (COPPA), which requires parental consent for online collection of personal information from children under 13.

You must obtain verifiable parental consent (“Consent”) from all parents whose children will be accessing our Services and provide a copy to us upon our request.

When obtaining Consent, you must provide parents with a copy of this Privacy & Security Policy.

You will only grant access codes to teachers and staff members who are current employees of your school or district. Upon termination of a teacher or other staff member’s employment with you, you will require such an individual to return and cease using all access codes he or she has in his or her possession. If at any time you learn a user of our Services claims to be affiliated with your school or district who is not, in fact, affiliated with your school or district, you will notify us immediately.

If you are accessing our Services as a Teacher, the following provisions also apply:

You confirm that you have permission from your school or district to enter into these Terms, to use our Services as part of your curriculum and that you have the authority to bind your school or district to these Terms and Conditions.

You confirm that you and your employer are solely responsible to comply with COPPA, which requires verifiable parental consent for online collection of personal information from children under 13.

You must obtain Consent from all parents whose children will be accessing ITG and provide a copy to us upon our request.

When obtaining Consent, you must provide parents with a copy of our Privacy & Security Policy.

If you are accessing our Services as a Parent, the following provisions also apply:

You will only use the login and password(s) provided to you by your child or children’s teacher.

You understand that your acceptance of these Terms and Conditions indicates that you agree to these Terms both on your own behalf as well as on behalf of your child or children who use ITG. Children under 13 must not use our Services until after a parent has accepted these Terms on their behalf.

Internet Privacy & Security

We and your school work together and take reasonable measures to protect the online privacy of the users of our Services, including students, parents, teachers, and administrators. Our information collection, security, and privacy policies have been authorized by your school or teacher, and we strive to manage your school’s EduWave services in a secure manner.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure, and due to factors beyond our control, we cannot ensure the security of the information we manage, whether transmitted to us by you, your school, or your teacher. For example, We may become legally obligated to disclose such data, or, despite precautions, third parties may circumvent security measures to intercept or access such data.

Information Collection & Use of your Personal Information

We collect and analyze data on how groups of people use our Services. For example, we might learn that certain parts of your school’s or school district’s hosted curriculum receive a disproportionately low volume of student traffic, which might influence how we recommend the presentation of materials in the future. [While the Named Subscriber through which you make access to our Service may use data consistent with its mission, we do not analyze information on how particular individuals use our Service in the usual course of our business other than to resolve technical matters or to assist in resolving or investigating any misuse of our Services.] From time to time upon request, we may furnish individual usage information to your school in relation to the investigation of fraudulent, abusive, or criminal activity or any other use of our Services that violates your school’s rules or policies.

We do not sell, share, rent, or trade your personal information with any third parties other than as disclosed within this privacy policy.

Parents have the right to consent to the site’s use of the child’s Personal Information without having to consent to its disclosure of that information to third parties by contacting the school administrator.

As required by your school as part of their information management efforts. For example, if your school uses a certain third-party company to manage their classroom scheduling and attendance system, necessary information may be shared with that company to assist in those administrative tasks.

These information collection, management, and disclosure practices apply to parents, teachers, administrators, and students. If you are a parent, you agree that this is acceptable for you as well as any of your children that use our Services. If you are a teacher, you agree that this is acceptable for you as well as any of your students that use our Services.

We do not share, sell, rent, or trade adult or children’s personal information with third parties other than as disclosed within this privacy policy.

We reserve the right to disclose your or your child’s personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site.

User-Generated Content

We do not control or monitor the messages, information, or files delivered to message boards made a part of our Services and any other user-generated content. You understand and agree that we have no obligation to monitor such message boards or other user-generated content. You also understand and agree that the Named Subscriber through which you make access to our Services may choose to restrict or monitor your access to message boards for any reason, and you agree to bound by any such restrictions or monitoring.

Both we and your school or school district reserve the right to disclose any information posted by you or any other user as necessary to satisfy any law, regulation or governmental request, or to edit, refuse to post or to remove any information or materials, in whole or in part, that in our sole discretion are objectionable or in violation of these terms and conditions.

Your school may use our Services to host forums for online discussion or message posting about issues important to your community or school. Your school will decide how these online forums are used, including whether they are available to students. These are public forums, and information that users post may be available to other members of the school community, and in some cases even other schools or the public internet. You should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of the forums, and could be used to send you unsolicited messages. Your school will decide how it wishes to use online discussion and message boards. We are not responsible for the personally identifiable information you choose to submit in these forums.

Private Messages

If you are a student, teacher, or faculty member you have the ability to chat with other students, teachers, or faculty members through private messages. Please be aware that any personal information you choose to share within these messages may be used by other members to send you unsolicited messages. We are not responsible for the personal information you choose to share within these messages. The chat permissions may be turned off or on for students under 13 by their school.

Both we and your school or school district reserve the right to disclose any information posted by you or any other user as necessary to satisfy any law, regulation or governmental request, or to edit, refuse to post or to remove any information or materials, in whole or in part, that in either our or your school’s/school district’s sole discretion are objectionable or in violation of these terms and conditions.

Publishing Content/Communications

You acknowledge that all communications on message boards and any other user-generated content are public and not private communications, therefore others may read what you say on the Internet without your knowledge. Please use caution when giving out any personally identifying information about yourself or your children on any message board. Educate your children as to the proper way to use a message board, chat room, and the Internet.

We do not control or endorse the content, messages or information found in any message board, and, therefore, specifically, disclaim any liability with regard to the message boards and any actions resulting from your participation in any on-line message board service. The managers and hosts of these boards are not authorized by us, and their views do not necessarily reflect ours.

Profiles

You acknowledge that your profile may be viewed by other users of the site; this includes your profile photo. Any information you choose to display on your profile may be viewed by other members of the site and may be used to send you unsolicited messages. Authorized individuals such as Teachers and School Administrators (as well as the Named Subscribers they represent) reserve the right to edit students’ profiles at any time by logging into their accounts and choosing the students to account they wish to update.

Testimonials

We post customer testimonials on our web site which may contain personally identifiable information. We do obtain the customer’s consent via email prior to posting the testimonial to post their name along with their testimonial. To request removal of your personal information from our testimonials, contact us at info@itgamerica.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Third-Party Content

We are a distributor (and not a publisher) of content supplied by your school or school district, third parties, and visitors. Accordingly, we have no more editorial control over such content than does a public library, bookstore, or newsstand. Any opinions, advice, statements, services, offers, or other information or content expressed or made available by third parties, including information providers, members, or any other user of this Service, are those of the respective author(s) or distributor(s) and not ours. Neither we nor any third-party provider of information guarantees the accuracy, completeness, or usefulness of any content, nor its merchantability or fitness for any particular purpose.

In many instances, the content available through our Service represents the opinions and judgments of the respective information provider, or the user and not necessarily that of us. We neither endorse nor are responsible for the accuracy or reliability of any opinion, advice, or statement made on our Service by anyone other than our authorized employees and spokespersons while acting in their official capacities. Under no circumstances will we be liable for any loss or damage caused by a user’s reliance on information obtained from us or through our Services. It is your responsibility to evaluate the accuracy, completeness, or usefulness of any information, opinion, advice, or other content available through this Service. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific information, opinion, advice, or other content.

Updating, Correcting or Deleting Personally Identifiable Information

If yours or your child’s personally identifiable information changes, or if you no longer desire our Service, you must contact your school (or, if such contact fails, then the Named Subscriber through which you make access to the Service) to correct, update, or delete it. If you are accessing the Services of EduWave individually (not through a school subscription) then you may correct, update, or delete the information by making available account changes using our Services by opening a support ticket in your account area or by emailing our Customer Support at CustomerSupport@itgamerica.com. We will respond to your request within 30 days.

We will retain User information for as long as an account is active or as needed to provide Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to our Privacy Policy

If we make changes to our privacy policy, we will post those changes on this privacy statement and on our home page. If we make material changes to how we use your Personal Information or Personal Information collected from children under age 13, we will notify you through your use of our Services, and if and as necessary by law, to parents by email in order to obtain verifiable parental consent for the new uses of the child’s Personal Information.

Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.

Links to Other Sites

If you click on a link to a third-party site, you will leave our website and be redirected to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personally identifiable information by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as do we. We encourage you to review the privacy statements of any other service provider from whom you request services. If you visit a third-party website that is linked to our web site, you should read that site’s privacy statement before providing any personally identifiable information.